Document xzDvLYoezmB7qgRbBQ41Vg3b6

FILENAME: Flintkote (FLK) DATE: 1972 June 14 DOC#: FLK041 DOCUMENT DESCRIPTION: Memo RE AIA/NA with Meeting Agenda The l in t k o t e c o m IKTEH-OFF7CE CORRESPONDENCE pan y / / fl /(yks$~<> Hr. John Szal AXA/TSA X. R. Hooker, Jr. June 14, 1972 I am attaching for each of you an announcement dated June 12 advising that XJA/NX's next meeting is to be held in He York City on June 22. I will attend the meeting as the Flintkote representative. In the meantime, X would like to call to your attention Pages 2 and 3 of the announcement which state the long range objectives of XIA as well as the principle topics that will be discussed at the forthcoming meeting. Z would like to have as much background information as possible concerning the studies that our Corporate Engineering Department have made in order that I can be as well informed as possible concerning Flintkote's over all potention problems, costs and ideas regarding the OSKA asbestos regulations. AAH:jo attachment co: Messrs. J. D. Horan with attachment V. N. Knorr I mtimLiiliiiitllliik t o * , jrnim m m m m m u mutmUlmi lih i , EXH IBIT. 2/7 | HOCXJmR-- 1 4-I2.-& Asbestos Infori^istion A sso ciation 22 East <0th Street Wow York. N. Y. 10016 212) E51-8205 June 12, 1972 merica 50 -CO . -<f. S g a j , a ) .kr>^^ TO: IA/NA KEM3ER COMPANIES AIA/NA ENV1RONKENTAL CONTROL SUB-COMMITTEE ` AIA/NA LEGAL COUNSEL James Armstrong E. C. Bratt - Bendix Corporation - H. K. Porter Company, Inc. G. G. Gabrielson, Jr. - Nicolet Industries, Inc. Bernard Gross - American Bilt Rite Rubber Company J. C. Harkins, Jr. - Congoleum Industries Inc. A. R. Hooker - The Flintkote Company C. A. Neumann Kentile Floors Incorporated G. w. Nickel - Armstrong Cork Company J. W. Rawlings - Union Carbide Corporation Clifford Seymour - The Carborundum Company Philip Weinstein - Evertex Incorporated G. W. Wright, M.D. - St. Luke's Hospital Gentlemen: On June 22, 1972, a special meeting of the Asbestos Information Associetion/North America will be held in the Biddle Room of the Harvard Club, 27 West 44th Street, New York City. The meeting will begin at 10 A.M. and will, continue through lunch. The purpose of the meeting is to discuss future industry action with regard to the new Federal- Occupational Safety and Health Administration (OSKA) standards on asbestos. Because of the generally reasonable regulations issued by OSHA and the 1976 effective date of the two fiber standard, the asbestos industry may be lured into a false sense of security and consider the OSHA battle to be over. This would be a most serious error to make. If we are to convince OSKA that the two fiber standard and other unfavorable sections of the regulations must be changed, then we must begin now to develop the medical, technical and economic evidence necessary to prove our point. In the introduction to the regulations on page 11318 of the Federal Register, it states: h ***** Au e n C l., Ci t w A i i e i n t N M t t U . . C * * Co t - Co t - Ci m o t Cj . N p^ wct Co t . f M i i m C l . Co t o t H i i m i i i mhwhww me. - 2- O "In view of the undisputed grave consequences from exposure to asbestos fibers, it is essential that the exposure be regulated now, on the basis of the best evidence availsbel now, even though it may not be as good as scientifically desirable. An asbestos standard can be revaluated in the light of the results of ongoing studies, and future studies, but cannot wait for them. Lives of employees are at stake.* The regulations can be changed, but it is up to the industry to prove to OSKA that changes are necessary and what those changes should be. It is desirable, therefore, for the AIA/NA to monitor ongoing studies and to encourage and support additional studies as are needed to: 1. Determine as precisely as possible over the next four years a safe numerical standard for the various asbestos-related diseases. *V?hile much <? t'r haadsditbieoennalaccsotmupdileissheadreinneetdheids. area in the past, Determine whether one or more varieties of asbestos is more or less hazardous than any other variety. 3. Determine through or.-the-job evaluation the technological feasibility of, achieving both five and two fibers throughout the industry. <. Determine the actual cost to the industry in both dollars and jobs of achieving two and five fibers. y/n 6. Determine the degree of reliability of the membrane filter method as a policing and moni toring tool in the asbestos industry. A proposal for an AXA/NA sponsored study in this area is presently under consideration. Develop other evidence as required to establish the necessity of additional changes in the regulations as deemed desirable by the industry. In addition to the above, other topics to be covered at the June 22 meeting will include: a. The overall.effect on the industry of the new standards. -More- 0 - 3- Programs of assistance for industry companies and customers to help them comply with the regulations. c. The establishment of a cooperative working relationship with OSHA with regard to the implementation and interpretation of the standares.. d. The advisability of legal action by the AIA/NA against OSKA, especially in light of (1) the four year effective date of the two fiber standard, '(2) the favorable decisions by OSKA on most other industry recommendations (see attached two page summary of OSHA acceptance of industry vs NIOSH and Advisory Committee recommendations), (3) the high cost (S3S0-S00,000) of such a suit, (4) the slin possibility of success, according to AIA/NA legal counsel, and (5) the adverse effect that such a suit would have on our working relationship with OSKA. With regard to point c. above, the AIA/NA is presently in the process of arranging a meeting with representatives from the standards development and enforcement sections of Of*HA to resolve some questions with regard to the interpretation of certain sections of the regulations. If your company has. any questions of this nature, please let me know as soon as possible so that they may be included on the agenda for our meeting with OSHA. it is the AIA/NA's intention to establish a continuing program of uniform standards ; interpretation witn OSHA, so~~that industry Questions ana I problems'mav**5e resolved ~at the nicnest levels in Waship.S.i.PTwt rather than through OSHA regional"" ofdices ~vhich may differ t in their standards ix.terpretation and enforcement practices from one region to another. Because of the relatively short time remaining before the . June 22 meeting, we would appreciate hearing from you as Q soon as possible whether you or a representative will be able to attend this most important AIA/NA planning meeting. * Sincerely, .T 7.'l7fl: K. M. Swetonic **r Executive Secretary Enclosure IH . i : JLlN i'l\ u i'K L-Lvil .N V INTER-OFFICE co rrespo n d en ce rVAINT1FP-S f eJCHIBTTr [ \zs i roc>K&z- FROM: S. Weiss White Plains DATE: September 27, 1972 SUBJECT: OSHA Bulletin #14 Asbestos Dust Hazard. Warning Signs The Asbestos Information Association has made arrangements to have Asbestos Dust^.Hazard warning signs printed. She signs will coniorm''tO""OSKA specincazions con-named ia Standard 1910.93 (g)(1) (ii) . If you wish to obtain the warning signs, you caa request them directly from Mr. A. R.Hooker, Jr. who is located at the White Plains office. i o'O T> c "V c- oh-oc G SoH2> VvjKi . ~ V<fi- ^oLxjuck. * CcX A*. jG U 'U Q 'tf